{"operation":"document","citation":"PI-18-0001","title":"Washington UTC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-09-27","effective_on":null,"summary":"PI-18-0001 response to Washington UTC concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/58051/washington-utc-pi-18-0001-09-27-2018-part-1923.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\nSEP 2 7 2018\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. Sean C. Mayo\nPipeline Safety Director\nWashington Utilities and\nTransportation Commission\n1300 S. Evergreen Park Drive, SW\nOlympia, WA 98504-7250\nDear Mr. Mayo:\nIn a December 8, 2017, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested an\ninterpretation for the definition of a transmission line under § 192.3.\nYou described the pipeline as a 76.53-mile-long intrastate transmission pipeline (Kettle Falls\nPipeline) operated by Avista Utilities. The pipeline receives gas from a connection with an\ninterstate transmission pipeline operated by Northwest Pipeline LLC (Williams) at\napproximately 5-miles north of Spokane, Washington and transports gas to north of Kettle Falls,\nWashington. You stated that other than the first 3.8 miles of the pipeline, the pipeline operates\nabove 20 percent of specified minimum yield strength (SMYS) and has historically been\nclassified as transmission pipeline by A vista.\nYou stated that the first 3 .8 miles, where the pipeline connects to the Williams transmission line,\noperates at 19.65 percent SMYS. You asked whether the 3.8-mile pipeline should be regulated\nas a transmission line since it operates at 19.65 percent SMYS and is tied into and receives gas\nfrom an interstate transmission pipeline.\n\"Transmission line\" is defined in § 192.3 as \"a pipeline, other than a gathering line, that:\n(1) Transports gas from a gathering line or storage facility to a distribution center, storage\nfacility, or large volume customer that is not down-stream from a distribution center; (2) operates\nat a hoop stress of20 percent or more of SMYS; or (3) transports gas within a storage field.\"\nNOTE: A large volume customer may receive similar volumes of gas as a distribution center,\nand includes factories, power plants, and institutional users of gas.\nEven though the first 3.8 miles of the pipeline operates below the 20 percent SMYS, the pipeline\nconnects to transmission lines at both ends and, therefore, meets condition 1 of the definition of a\ntransmission line.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CPR\nParts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nA pipeline that meets any of the three conditions listed under the definition in § 192.3 is a\ntransmission line in accordance with 49 CFR Part 192. Therefore, a pipeline that operates at a\nhoop stress ofless than 20 percent of its specified minimum yield strength, but meets either\ncondition one or three, meets the definition of a transmission line.\nPHMSA agrees with Washington Utilities and Transportation Commission that the 76.53-mile-\nlong pipeline, including the first 3.8 miles of the pipeline, is a transmission line. If we can be of\nfurther assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJo e\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the fonn ofinterpretation letters. These letters reflect the agency's current application of the regulations to the .\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the r, egulations.\n\n<<<PAGE 3>>>\n\nSTATE OF WASHINGTON\nUTILITIES AND TRANSPORTATION COMMISSION\n1300 S. Evergreen Park Dr. S.W., P.O. Box 47250 • Olympia, Washington 98504-7250\n(360) 664-1160 • TTY (360) 586-8203\nDecember 8, 2017\nJohn A. Gale\nDirector of Standards and Rulemaking\nOffice of Pipeline Safety\nRoom 24-310\n1200 New Jersey Ave, SE\nWashington DC 20590\nRE: Request for Interpretation of \"Transmission Line\" as defined in §192.3\nDear Mr. Gale:\nWe are requesting an interpretation as to whether the first 3.8 miles ofthe below described 76.53\nmile AvistaUtilities' (Avista) Kettle Falls Pipeline should be considered \"Transmission\" as\ndefined in §192.3 Definitions, Transmission Line, (1). We consider definition (1) to be a\nfunctional definition of Transmission.\nTransmission line means a pipeline, other than a gathering line, that: (1) Transports gas\nfrom a gathering line or storagefacility to a distribution center, storagefacility, or large\nvolume customer that is not down-streamfrom a distribution center; (2) operates at a\nhoop stress of20 percent or more ofSMYS; or (3) transports gas within a storagefield.\nThe Kettle Falls Pipeline begins approximately 5 miles north of Spokane, WA at the point where\nNorthwest Pipeline LLC (Williams), an interstate transmission pipeline operator, delivers natural\ngas to Avista through a tap at their 9-Mile Gate Station. At the 9-Mile Gate Station, the gas is\nmetered, odorized^, the pressure is reduced, and over-pressure protection is provided. The\npipeline runs 76.53 miles, transporting gas to various regulating stations along its route until it\nreaches its end point north of Kettle Falls WA. From the delivery point at 9-Mile, the pipeline is\nconstructed primarily of 3.8 miles of 12-inch, 0.312 w.t., X-52 (19.65 percent of SMYS), 60.505\nmiles of 8-inch, 0.188 w.t., X-42 (27 percent of SMYS), 12.09 miles of 6-inch, 0.156 w.t. X-42\n(25 percent of SMYS), and 0.135 miles of 4-inch (<20 percent SMYS) to its end point north of\nKettle Falls WA. It has a Maximum Allowable Operating Pressure (MAOP) of 500 psig.\n' Avista Utilities is an intrastate Local Distribution Company operating in Washington, Idaho and Oregon that is\nbased in Spokane WA.\nuser.\n^ WA State requires odorization of all pipelines transporting natural gas unless it makes the product unfit for the end\nRespect. Professionalism, integrity. Accountability.\n\n<<<PAGE 4>>>\n\nIn 2010, the first 1.7 miles of 8-inch transmission line were replaced with 3.8 miles ofheavier\nwall 12-ineh due to residential encroachment and for additional flow capacity. Prior to the\nreplacement the entire 76.53 mile segment ofpipeline, from the 9-Mile Gate to its end point,\nwith the exception ofthe 4-inch at the end, was operating above 20-percent of SMYS and was\nclassified as transmission by Avista. After the replacement in 2010, Avista reelassified the 3.8\nmiles of 12-inch as high-pressure distribution rnain since it was operating at less than 20 percent\nof SMYS (19.65 percent). The remaining 72.73 miles ofpipeline continues to operate above 20\npercent of SMYS and is classified as transmission by Avista. See maps - Attachments A and B.\nOur question to you is as follows:\nSince the above described 3.8 mile segment of 12-inch pipeline, operating at 19.65% SMYS, is\ntied into and receives gas from an Interstate Transmission Pipeline and transports the gas to an\nIntrastate Transmission Pipeline, do you believe that the 3.8 mile segment meets the functional\ndefinition of Transmission as found in §192.3 Definitions, Transmission Line, (1)?\nIf you have any questions or if we can provide further clarification or details, please contact\nScott Rukke at (360) 664-1241 or Joe Suhsits at (360) 664-1322.\nSincerely,\nSean C. Mayo\nPipeline Safety Director\ncc: Huy Nguyen, Acting Director, Western Region, PHMSA\nEnclosures\n\n<<<PAGE 5>>>\n\nAttachment A\nKettle Falls Transmission Map\nSegment 18\nKettle Falls\nW\nE\nSegment 53\nGolville -\nSegment 17\n• Segment 16\nPend Oreille\nInchelium\nChewelah\nFerry\nChewelar\nSegment 50 & 51\nStevens\nWashington\nSegment 40\nSpringdale\nSegment 5\nDeer Park\nSegment 4\nLegend\nSee attachment B for an enlarged\nmap of area circled in red.\nForeign Pipe Lines\nCompany\nAvista\nWilliams\nNW Towns\nSegment 3\nNWCounties\nSegment 2\nFairwood\nNWStates\nLincoln\nSpokane\n5 Stn: 8008\n213, 1, i, i\n10 Miles\nSegment 1\nSpokane\n\n<<<PAGE 6>>>\n\nAttachment B\n9 Mile City Gate to Kettle Falls Transmission\nN Indian U\nBlackfoot Ave\nrail Ro\nBedford Ave\nHighway 291\nSpokane River\nW Parkway Rd\nN Pine Meadows Rd\nLegend\n• Transmission\n9 Mile City Gate Station\nHigh Pressure Distribution\n0.125\n0.25\n0.75\nAVISTA\nUtilities\nNOTICE THIS IS NOT\nA LEGAL DOCUMENT\nLocations of Avista Utilities' facilities on this map are approximate only\nChanges to facilities may have occurred since the last update of this\nmap.\nbefore start of work\nkeview ormis map is notan acceptable subswute tor compilance\nRoute To: Dylan Karaus\nPrinted: 11-14-2017\n1 inch = 750 feet","truncated":false,"body_characters":8893}